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Home My WebLink About04-3933 F:\User Folder\Finn Docs\Gendoc~2004\3395-1diY,comp,wpd IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SPENCER L. CLARK, Plaintiff v. CIVIL ACTION - LAW NO.2004- 3933 LISA A. CLARK, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown ofthe marriage, you may request marriage counseling. A list of marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements ,md the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days ofthe date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LA wn:R OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA SPENCER L. CLARK, Plaintiff v. CIVIL ACTION - LAW NO.2004- 3'133 LISA A. CLARK, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this 11/'" day of August, 2004 comes Plaintiff, Spencer L. Clark, by and through his attorneys, Hanft & Knight, P.C., and files the folJowing Complaint in Divorce, and in support thereof avers as folJows: 1. The Plaintiff is Spencer L. Clark, who resides at 847 Lindsay Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Lisa A. Clark, whose residence is unknown and whose last known mailing address is P.O. Box 2581, Chattanooga, Tennessee 37409. 3. The Plaintiff and Defendant are sui juris, and Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. 4. The parties were married on October 30, 1992, in Mt. HolJy Springs, Cumberland County, Pennsylvania. 5. The marriage is irretrievably broken. The foregoing facts are averred and brought under Section 3301(c) of the Divorce Code of 1980, as amended, 6, The Plaintiff has been advised ofthe availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling, and Plaintiff waives same. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the P1aintifffrom the Defendant. Respectfully submitted, HANFT & KNIGHT, P.C. ~A Sean M. Shultz, Esquire Attorney ill No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 ------ Attorneys for Plaintiff . . VERIFICATION [ VERIFY that the statements set forth in the attached document are true and correct to the best of my knowledge, infonnation and belief. [understand that false statements herein are made subject to the penalties of 18 Pa. Section 4904 relating to unsworn falsification to authorities. t~J '- x!:-x s~rk' F \l:~( Foldo:r'r.nn DoXl'Fcnn$\LiliSldon\Vcrilicu;gt'l gctlcnc C) '^=:) 0 '-4. ~, - ~, ~ ~ 0 <S'- vI - '0 <> "" ~ ~ -e. "+::.. -~'. VI ~. s:> -:> -+-) ...... -+ ~ '''''-is '=1=-, 0 ;,;- I' ~ ~ @ 1",-1 --- c-' r:~ r..,) <...' , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SPENCER L CLARK, Plaintiff v. CIVIL ACTION - LAW IN DIVORCE LISA A. CLARK, Defendant No. 2004-3933 PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please Teinstate the Complaint in Divorce that was filed in this matter. Date: October 27,2005 By: ean M. Shultz; squire Attorney LD. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17013 (717) 249-5373 Attorney for Plaintiff F; I,User FotdcrlFillTl Ooc~\Gendocs2005\3395_1 praecipe. reinstate. wpd ~ ~ ~ \ q ~;. < -ui)5 q;t~.t -:::;;r" ~3.[~~ ~\(:~ 7C, ._-,? ,,~ 2 ~ ..... ~;:!:l i;:;j :Be;:> (:.),c, ;-Jr't'_i )5:~ Zfr\ 0. _A ~ - ~ '-P. C> UJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANL\. SPENCER L. CLARK, Plaintiff v. CNIL ACTION - LAW NO. 2004-3933 LISA A. CLARK, Defendant IN DNORCE ACCEPTANCE OF SERVICE I, Lisa A. Clark, the Defendant in the above captioned matter, heTeby accept service of the Complaint in Divorce filed on August 10, 2004, and reinstated on November 1, 2005, in the above captioned matter. Dated: //_/0 - ,,-2 dioo () cQn^~ Lisa A. Clark \\\\,UII'U'1I11/. "" ",:{J.\N E I ~"" ~~.~\..........";C~~ $ '.... ...<.p~ 1 l NOTARY .... ~ ~: PUBLIC : ~ :: AT :: u'1R'/~~~ \ \. LARGE ./ I -f./.-:;//.;:fJ!~'~ _~ ~ ~.... ...~ ~ ~ ~ ..~:.~-\'-'~ ;fI'l, UJlJI'f. \ ~ \",,, "'llIum..U\\" iI-/e' -<95 FIUser Folder\Film DocsIGendocs2005\339S-1acceptscrvice wpd ; .. O>>"'",r.:mON EXfIRES: : .~y 21. 2007 ,':J r,,,; , , o~' c..:' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SPENCER L. CLARK, Plaintiff No. 2004-3933 In Divorce v. Civil Action - Law LISA A. CLARK, Defendant AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA ) : SS. ) COUNTY OF CUMBERLAND 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 10,2004 and reinstated on November I, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S., Section 4904 relating to unsworn falsification to authorities. ~ ~ \ . 11 b' / Date: Nov, 20 ,2006 ~_ /- tY~ Spencer L. Clark COMMONWEAL TH OF PENNSYLVANIA Notarial Seal MJ:::. Housel, NotaIy Public My~.' Cumbed8ndCounty M Ellpires Sept. 24, 2010 ember, Pennsylvania Associ 110 a n of Notaries 2 ~ ~ ~ ~ a ~:n ~~ ;;;.c:: :o~ ~c;: ....., 66 2.... CP ~b ~-r, ~ ~ -1"1 0-- ~c ?5'if. ;; ("\ - e - ~ ~ ., ~ - (j> INTHECOURTOFCO~ONPLEASOF CUMBERLAND COUNTY, PENNSYLVANIA SPENCER L. CLARK, Plaintiff No. 2004-3933 In Divorce v. Civil Action - Law LISA A. CLARK, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy ofthe decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. Date: lllzololt s~ll' tI~ ~ -061 tJl~~. m~-: ~.<.. 'L.C ~G ,__:,0 ;PC ~ ~ ~ ~ ~ ~ ~ - - .' ~ ~\ ::::;.\ -T'. :t:-n q,5 o~ ::;:.\ - ~ CF" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SPENCER L. CLARK, Plaintiff No. 2004-3933 In Divorce v. Civil Action - Law LISA A. CLARK, Defendant AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA ) : SS. ) COUNTY OF CUMBERLAND 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 10,2004 and reinstated on November 1,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 4. I have been advised ofthe availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S., Section 4904 relating to unsworn falsification to authorities. 0 Date:~f'(/~ 1:5~ ,2006 ~O Q Clr1.J Lisa A. Clark Sworn to and subscribed before me this I ~ day of ,P; <.J A 2006. ~,,\\\Ul"'''''11. / ~\\'\.\~\N E ! l' ~11;l 1/t;~' ~ ~^\"".ooooo~o.~~~ ~ #' ~~.o 00.19 ~ ~ ..0 NOTARY 00. ~ ----~. .'::- otary PublIc, i i PUBLIC ; i . .~ONEXPIRES: i ~ AT : i . _.. .." a7,a007 \ .... LARGE l j '- .... ..~ ~ F:IDser F?JderIFirm DocslGendoes2006\3395.laff'consent.wpd -, ~!o.~~':.~ ''''-.ff I""~~\:\\\~ ~/"'''IIt",,,,\'\ ~ -0 CD rt} fr: Z,:-J-' -..;rr ~~-- {nJ..- :..c:,,, ~C' ZO ~O rC ~ ~ ~ 5 ~ '" OJ ~ - - .. ~ ~a -;.QQ ~tli -.:k;\;l ~,'ri' g ~ - C1" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SPENCER L. CLARK, Plaintiff No. 2004-3933 In Divorce v. Civil Action - Law LISA A. CLARK, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 13301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date: ;1btJ~ I~ ;Zt:?C:>6' rlihO Lisa A. Clark Q (2f!,-(WL /1""/5-&6' BUser Folder\F"um Doos\Gend0cs2006\3395-1 waiver, notice, wpd \""\'''''"1111'' l\~~~~N E l I'II~ ~l'~. ,,~';;O. ..,N EXrlMI\ ~~.~.-.........~/f;~ #' , ..- -.. ij't ~ ~ ... NOTARY ... ~ ~ . . ~ i : PUBLIC : ~ - . . - =:, AT :: \ \. .. i ~ .. LARGE ... ~ ~ ~.. ".A. ~ ~~ ....~:.~ -"-'~ 1"11 !,).}.}:I.\:' 'I\\~ ~/I"""'I"I"'\'\ ~ ~ o ~ -i ~- ~ ~~ --Q. ~ ~ '"'0 0 ~Jq., ~ tSb ~ \1'" fP ~~-\ (;1"'7' _ """ ~ (.'1 ~ '% 'ffI I.C: __ ~ 9 l\ ~ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SPENCER L. CLARK, Plaintiff v. CIVIL ACTION - LAW No. 2004- 3933 LISA A. CLARK, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section 330 1 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: served on Defendant by United States Mail on November 10, 2005 by Defendant signing and Acceptance of Service. 3. Date of execution of the Plaintiff's Affidavit of Consent required by Section 3301 (c) of the Divorce Code; November 20,2006; by the Defendant; November 13,2006. 4. Related claims pending: None. 5. Date Plaintiff's Waiver ofNotice in g330 1 (c) Divorce was filed with the Prothonotary: November 22, 2006. Date Defendant's Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: November 22, 2006. KNIGHT & ASSOCIATES, P.C. ,Y--/-15 Date: November 21, 2006 Sean M. Shultz, Esquire Attorney J.D. No. 90946 11 Roadway Drive, Suite B Carlisle, Pennsylvania 17015 (717) 249-5373 Attorneys for Plaintiff F,IUser Folder\Firm DocslGend0cs2006\339S-1 pnlocipe, wpd 2 -; "'0 I."):! mf'n z'::P 7AIJ:.; :::.<('!' t.2. C' zC:, _-c ~'~ ~ ~ a ;;;.c ~ ~ ~~ ~~\ ~..:( - ~ ~ %~ :::: :::.-l .:: ~ 0"\ ;t; ;t; ;t;;t; Of. Of. Of. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNA. STATE OF SPENCER L. CLARK, Plaintiff No. 2004-3933 VERSUS LISA A. CLARK, Defendant DECREE IN DIVORCE cT /.'3~f.HI. AND NOW, ~~ 2006 , IT IS ORDERED AND DECREED THAT SPENCER L. CLARK , PLAINTIFF, AND LISA A. CLARK , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; N1A ATTEST: PROTHONOTARY ;t;;t; ;t;Of. Of. ;t; ;t; ;t; ;t; ;t; Of. ;t; ;t; J. . ~ ~ ~ ~~ 1~' L - 'L/ ~r?~-~-/p '/Q.L'el ..' ~ , ,.' '-A